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When questioned by ICOS, yesterday in Brussels, Commission officials confirmed that their proposals for the spreading 2014/15 super levy bills over 3 years were still on track. The proposal was supported by Member States at a Council Working group today, and is expected to be endorsed by the College of Commissioners over the coming week. If it gets the go ahead from the Commissioners, it will then proceed to publishing in the Official Journal. That all needs to happen, however, before March 31st, as no changes can be made to the legislation from April 1st onwards. Assuming it succeeds, then the real work begins, as Member States need to legislate and put in place structures at national level, allowing them to borrow money, effectively to lend to farmers to pay their super levy bills. As well as the obvious complication of such a structure, the various Departments of Agriculture will need to put in place facilities to check whether benefiting from the super levy instalment scheme would contravene State Aid Rules at individual farmer level. Under State Aid rules, individuals are not permitted to benefit from state aids in excess of €15k over a three year period. While the benefit accruing from avoiding interest payments on a super levy bill might not approach the €15k limit, even in exceptional cases, the actual figure needs to be combined with the value of other state aids, such as under various Pillar 2 programmes.

A contract would also need to be drawn up, to be signed by farmers applying to benefit from the Scheme, to ensure that the Member State is guaranteed payment of tranches 2 and 3 of the super levy bill.

All the above work needs to be done and the Scheme provided for in law before co-ops could consider amending their current approach to super-levy collection.